Ajuba Gaylord - Page 8

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               1.   Office Expenses                                                   
               Petitioner contests respondent’s disallowance of $3,545 in             
          deductions for office expenses incurred during 1999. These                  
          expenses include, according to petitioner’s testimony and                   
          receipts she produced, outlays for music CDs, videos, home                  
          cleaning products, packs of Kleenex, napkins, a laptop computer,            
          computer hardware, batteries, certain office supplies, and                  
          postage.                                                                    
               At trial, petitioner presented receipts and bank statements            
          to substantiate her office-related expenses.  Some of the                   
          receipts simply indicate the amount paid but do not contain any             
          itemization from which the nature of the items purchased can be             
          ascertained.  The only available evidence to that effect is                 
          petitioner’s own self-serving testimony, which we are not                   
          required to accept, and which we do not, in fact, find to be                
          credible.  See Niedringhaus v. Commissioner, 99 T.C. 202, 219               
          (1992).  Thus, with regard to the expenses for which there are no           
          adequate receipts, petitioner’s claim fails for lack of                     
          substantiation.                                                             
               With respect to expenses that are supported by adequate                
          receipts, there are items we find to be related to petitioner’s             
          business and therefore deductible.  These are expenses for office           
          supplies, totaling some $44.4  Additionally, while petitioner               

               4 These comprise expenses for bookmarks, markers, writing              
                                                             (continued...)           




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